Thursday, 3 November 2016

Cigarette are laden with them. Alcoholic drinks too. So are gambling products. I’m talking of course about health warnings.

In these industries, companies must add warnings to their adverts. They must let people know if there is a risk if consumers use their products.

The same is true for advertising financial products.

Let’s have a look at some examples.

The mortgage lender

The most common one you’ll see is:

Your home may be repossessed if you do not keep up repayments on your mortgage.

You might find this with HSBC, Barclays Bank or Halifax. When most people read this, it is often in smaller print. It is reasonably clear what this means. But could the warning be even clearer?

If you do not pay your mortgage on time, we may take away your home

If you make the passive voice active, you draw your reader’s attention quicker.

The short-term lender

If you take the London tube, you might see:

WARNING: LATE REPAYMENT CAN CAUSE YOU SERIOUS MONEY PROBLEMS. FOR HELP, GO TO MONEYADVICESERVICE.ORG.UK

This looks like a warning on a beer bottle. You understand it when you read it. Payday lending companies are only too aware of negative press. So they chosen to be more direct and responsible.

The property investment company

Like most investments, you may get back less than you put in.

This is simple, clear and direct. It lets potential investors know: you can lose money as well as gain. It certainly wouldn't scare away any potential investors. And it is not hidden away in the terms and conditions.

CONCLUSION:

Generally, I believe that the warnings are clear and suitable for their audience. Advertisers need to promote their product and not scare off customers.

However, warnings are only a small part of the advert. The Financial Conduct Authority’s guidance sums this up well:

Financial advertising and promotions should clearly explain what the product or service is, how it works and how you could benefit from it.

It must also be clear about the costs involved and whether there are any risks to your money.

Do you have any warnings on financial products? If so, do share them !

WARNING: In this blog, I am only looking at warnings on adverts from a plain language perspective. This does not mean I am for or against any financial product or company.

“Shall that portion of 2013 Wisconsin Act 14 which limits the compensation of members of the board of supervisors of Milwaukee County other than the chairperson of the board and chairperson of the finance committee to receipt of an annual salary of not more than the annual per capita income of this county, which in 2012 was $24,051, and which limits the compensation of the chairperson of the board to not more than 150 percent of that amount and the chairperson of the finance committee to not more than 125 percent of that amount, subject to limitations and adjustments specified by law; and which prohibits supervisors from receiving any compensation or benefits not specifically authorized or required by law become effective in this county on April 18, 2016?”

In Ethics, you have something called the “smell test”. If something smells fishy, then something is morally wrong.

Here you could apply the “breath test”. Can you read the question in one breath? Yoga instructors and swimmers aside, I would be struggling to read this in 3 whole breaths!

Yes, it is a real-life example. It is one sentence which has 129 words. Separated only by a single semi-colon.

I’d be interested to know the legal arguments why the question was like this. We don’t know about local politics issues. But as someone from outside, I would find it difficult to justify this as plain and understandable.

That said, the question does come later with an explanation:

“EXPLANATION

A Yes vote will limit salaries and benefits for the Milwaukee County board of

supervisors beginning in April 2016. A supervisor’s salary and authorized benefits will be capped at the annual per capita income of the county, which was $24,051 in 2012.

Compensation will be limited to 50 percent more than the supervisor’s amount for the Board chairperson and 25 percent more for the finance committee chairperson.

A No vote means the limits on salaries and benefits will not take effect. “

The Milwaukee County board could have saved time by first explaining the issue. Then ask the citizens whether they want the change. I would re-write this as:

“THE ISSUE:

The Milwaukee County Board is asking its citizens to vote on the supervisory board’s salaries and benefits. It is proposed that :

- a supervisor’s salary and authorized benefits are capped at $24,051. That was the average income per person in the county in 2012.

- the compensation of the Finance Committee chairperson will be at most 25% higher than a supervisor’s salary.

- the Chairperson’s compensation will be at most 50% higher than a supervisor’s salary.

If voters approve, these changes to salaries and compensation will take effect from 1 April 2016.

Should the proposed changes to compensation and benefits take place?”

Of course, you’d need to test this with local citizens to see if they understand the question.

At least here, you can say that the question is short, clear and understandable for the Scottish voters. Indeed, whether this is politically neutral is another point. You could say that voting “no” leads to negative campaigning.

Monday, 31 October 2016

You'll read a lot about why it's good to write in plain language. But how do you actually write in plain language? The two simplest things you can do are:

- reduce sentence length to 15-20 words

- make the passive voice active

However, you don't want to spoil the flow. Or make a sentence sound just plain weird. One example when it's fine to use the passive is here:

We are regulated by the Financial Conduct Authority

Here, "we" - the regulated company - is more important than the Financial Conduct Authority. So it is better to keep this passive.

You might think something fishy is going on if you saw:

The Financial Conduct Authority regulates our services

And now it's time for you to see a plain language rewrite. This is a press release from OFCOM, the British communications regulator.

Original

Promoting competition and investment in superfast broadband

Ofcom has today notified new measures to promote competition and investment in the growing market for superfast broadband.

Under a draft decision notified to the European Commission today, a new pricing rule would mean that BT must maintain a sufficient margin between its wholesale and retail superfast broadband charges in order to allow other providers profitably to match its prices.

The new pricing rule would preserve BT’s current flexibility to set its wholesale fibre prices, which in turn provides an incentive for future investment by the company in its fibre network. At the same time, the rule would mean BT could not set prices in such a way that might prevent other operators from competing profitably for superfast broadband customers.

BT is currently the largest retail provider of fibre broadband services over its network, but is required to allow other operators to use its network to sell superfast broadband to consumers under a process known as ‘virtual unbundled local access’ (VULA).

The draft regulatory condition notified by Ofcom to the Commission would require BT to ensure that the margin between its wholesale VULA charges and its retail superfast broadband prices is sufficient for rival operators to compete and make a profit.

Ofcom’s indicative assessment* is that BT is maintaining a sufficient margin under the new draft rules. Therefore, the condition is a safeguard which limits BT’s ability to reduce retail margins in future, and ensures that any increases in BT’s costs must be reflected in its prices.

BT currently provides BT Sport free to its superfast broadband customers, and the new rules take into account the costs and revenues of these sport channels, as well as other elements included by BT in its retail superfast broadband bundles.

The growing superfast market

When Ofcom introduced the requirement for BT to allow other operators to use its upgraded fibre network, there were fewer than 100,000 superfast broadband connections on this network.

That number has now risen to around 3.4 million, with providers regularly offering speeds of up to 76 Mbit/s, and take-up is expected to increase further over the coming years. Looking ahead, industry and policy-makers are also considering how the next generation of ‘ultrafast’ broadband services - which will provide speeds around 1 Gbit/s - can best be achieved. This may involve further investment to upgrade the infrastructure currently used to provide superfast broadband.

Today’s draft decisions are aimed at ensuring that different operators can compete in the developing broadband market in years to come, so that consumers benefit from competitive prices, network investment and high-quality, innovative services.

The measures are subject to review by the European Commission. Following this review, Ofcom expects to publish a final statement in February 2015. The new regulatory condition would commence from the beginning of March and remain in place until March 2017, when the current regulatory review period ends.

A statement on today’s draft measures is available online.

NOTES FOR EDITORS:

* Ofcom’s indicative assessment of BT’s compliance with the draft condition uses data sources from a mix of years, so the assessment will not precisely reflect the current position.

Ofcom’s principal duty under the Communications Act 2003 is to further the interests of citizens in relation to communications matters, and to further the interests of consumers in relevant markets, where appropriate by promoting competition.

Plain language version

What we’re doing to increase competition and investment in superfast broadband

Today, we announce new ways to make broadband companies invest more in the superfast and increase the number of providers in this market.

The European communications regulator announced that BT must keep a sufficient difference between what it pays and what it sells for superfast broadband. This will allow other providers to match its prices and make a profit.

BT would still be able to set the selling price for other high speed broadband providers. This would encourage BT to invest more in its network and allow other broadband providers to compete for customers and make a profit.

BT currently has the most number of customers in the UK for broadband over its network. However, it must allow other providers to use its network to sell superfast broadband to consumers.

We have now recommended that the European Commission should adopt the European communication regulator’s proposals.

From our study*, we believe that BT can still make a sufficient profit in the new setup. As a result, this ensures that if BT’s costs increase, then this increase will also show in its selling price for superfast broadband.

BT currently provides BT Sport free to its superfast broadband customers. The new rules consider the income and costs from these sport channels and also from its other broadband deals.

The growing superfast market

When we required BT to allow other broadband providers to use its improved network, you had fewer than 100,000 superfast connections.

You now have around 3.4 million connections and providers regularly offer speeds of up to 76 Mbit/s.

At this speed, you can download one CD of songs in just over a minute. We expect more people to use superfast services in the future. The industry is already considering how it can achieve speeds of around 1 Gbit/s.

At that speed, you could download one CD of songs in 5 seconds. We think that this will make broadband providers invest more in the superfast network.

Our announcement today allows broadband providers to compete and to invest more in the network. Consumers will gain more from lower prices and quicker and better services.

The European Commission will review our proposals. We will make our final statement next month. The new rule starts in March and will last until March 2017. That's when the current review of regulation ends in the broadband market.

You can read more about our announcement here.

NOTES FOR EDITORS:

* Our study of how BT would comply with the new rules uses data from various years. You should not assume that it represents the current situation.

Our main duty is to enforce the Communications Act 2003. We make the communications market more competitive and we protect consumer interests.

A few points:

- In the end, I managed to reduce this by almost 100 words!

- I have not simplified "superfast" - as this is the main topic of the article. If you must use jargon, explain it!

- Average sentence length has gone down from 26 words to just under 15 words.

Would you like to know some more plain language tips? Send me an e-mail: info@neelangues.com